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On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”).

Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt Practices Act of 1977, as amended (the “FCPA”), and signaled a coming shift in how the statute will be enforced in the future.

As Donald J. Trump prepares to begin his second presidential administration on January 20, 2025, many Department of Justice (“DOJ”) priorities and policies are likely to change.

As we approach Inauguration Day on January 20, 2025, one question among anti-corruption practitioners is how the Trump administration will handle enforcement of the Foreign Corrupt Practices Act (“FCPA”).

On January 10, 2024, the United States Attorney’s Office for the Southern District of New York (“SDNY”) introduced the SDNY Whistleblower Pilot Program (“Pilot Program”), aimed at encouraging individuals to disclose information about specific criminal offenses, particularly urging them to do so early and voluntarily. In return for their cooperation, SDNY will enter into a non-prosecution agreement (“NPA”) if certain conditions are met.

In a long overdue move to fill a perceived gap in U.S. law, this year’s National Defense Authorization Act included a new law that will finally criminalize the solicitation of bribes by foreign officials.

Earlier this month, a federal judge vacated two convictions related to the Department of Justice’s (“DOJ”) investigation into corruption in international soccer, widely known as the “FIFA Case.”